Inordinate Delay by State Cannot Be Condoned Mechanically Without Establishing Sufficient Cause Within Limitation Period.

The State of Chhattisgarh sought leave to appeal against a judgment dated 12.04.2019 passed by the Sessions Judge, Bemetara, which acquitted five respondents of charges under Section 306 of the IPC

The State filed the present petition with a delay of 1752 days beyond the prescribed limitation period

The State attributed this delay to the fulfillment of various departmental formalities, the multi-functional nature of government machinery, and the time required for the Law & Legislative Affairs Department to process the proposal through the Advocate General’s office

Whether the provisions of Section 5 of the Limitation Act apply to an application for leave to appeal an order of acquittal and whether the State established "sufficient cause" to condone a delay of 1752 days

The Court applied the principle of "sufficient cause" under the Limitation Act, emphasizing that while the State is a large machinery, it does not enjoy a separate or longer period of limitation than private litigants

It relied on Postmaster General v. Living Media India Limited (2012) 3 SCC 563, which held that government departments have a special obligation to perform duties with diligence and that "procedural red tape" is an unacceptable explanation for inordinate delay

It further applied State of Madhya Pradesh v. Ramkumar Choudhary (2024) INSC 932 and Ajit Singh Thakur Singh v. State of Gujarat (1981) SC 733, establishing that "sufficient cause" must be traced to circumstances arising within the original limitation period, and negligence or lack of bona fides precludes discretionary relief

The Court reasoned that the State’s explanation was generic and lacked specificity regarding the nearly five-year delay.

It observed that modern technology renders the "bureaucratic methodology" excuse obsolete and that the law of limitation binds the Government equally

The Court analyzed the timeline provided by the State and found it failed to explain why it was unable to institute proceedings between the 1st and 90th day of the limitation period, noting that circumstances arising after the expiry of limitation do not constitute "sufficient cause"

The Court held that the State’s pursuit of the matter was characterized by a "callous and lackadaisical attitude," and condoning such a massive delay without a cogent reason would cause undue prejudice to the acquitted respondents

The petition for leave to appeal was rejected solely on the grounds of delay and laches

Additionally, following the mandate in Ramkumar Choudhary, the Court directed the State to fix responsibility and penalize the officers responsible for the lapse to recover the value of the loss caused to the Government exchequer